1. Controller
Artifio OÜ, Sepapaja 6, 15551 Tallinn, Estonia, registry code 14512956, represented by Giray Songül, email [email protected]. For questions about your data in Sprachtest Einbürgerung, write to [email protected]. We have not appointed a data protection officer, as we are not required to.
2. In short
- We collect only what we need to run the Service: your account, your learning progress and what you send to the AI features.
- We use no tracking or advertising cookies, and we do not sell your data. We measure how the website and the app are used with PostHog, without cookies (section 3).
- Our servers and database are in the EU (Amsterdam, Netherlands). Some service providers are based in the USA; section 10 explains how transfers are protected.
- Texts, photos and recordings you send to AI features are processed by AI providers to create the feedback. Photos of handwritten messages are not stored.
- Questions to the study assistant are kept for 30 days to check and improve its answers, then deleted.
3. Visiting the website
When you open a page, your browser sends technical data: IP address, date and time, the page requested, referrer, browser and operating system. Our network provider Cloudflare (DNS, encryption, protection against attacks) and our hosting provider Railway process this data to deliver the pages and keep them secure, and keep server logs for a short time. Legal basis: our legitimate interest in a secure and working website (Art. 6(1)(f) GDPR).
Usage statistics: to understand how the website and the app are used and to improve them, we use PostHog (PostHog, Inc., USA) with servers in the EU (Frankfurt, Germany). PostHog records the pages you open, the referring page, clicks on buttons and links, actions such as completing a task, a mock test (with the estimated score) or a flashcard round, installing the app, errors on the page, whether the app runs installed, your browser, operating system, device type, interface language and approximate location (country and city, derived from the IP address). It sets no cookies and stores nothing in your browser: visitors are counted with a hash of the IP address, browser data and a value that changes every day, calculated on PostHog's servers, so you are not recognised from one day to the next. IP addresses are not stored.
When you are signed in, our server also sends PostHog a few events with your account ID (not your name or email address): completing sign-up, the days on which you use the app, each AI feedback and assistant request (feature, task, estimated points, model and cost; never your text or recording) and reaching a daily limit. Legal basis for the usage statistics: our legitimate interest in understanding and improving the Service (Art. 6(1)(f) GDPR). You can object to this (section 12).
4. Cookies and storage in your browser
We only use storage that is strictly necessary for the Service. It does not need consent (Art. 5(3) ePrivacy Directive and the national laws implementing it). Our usage statistics (section 3) work without cookies or browser storage.
| Name | Purpose | Duration |
|---|---|---|
| Session cookie (better-auth.session_token) | Keeps you signed in | Up to 30 days after your last visit, or until you sign out |
| better-auth.admin_session | Only for our team: keeps the team member's own sign-in while they view the app as a user (section 5) | Until the support session ends |
| lang | Remembers your interface language | 1 year |
| Local storage: berlin-study-app-v1 | Copy of your progress, so the app works quickly and offline | Until you sign out or clear your browser data |
| Local storage: theme, chat-mode | Light/dark theme and layout of the study assistant | Until you clear your browser data |
| Cache storage: offline-v1 (service worker) | A page without personal data that the app shows when there is no internet connection | Until you clear your browser data |
| IndexedDB: sprachtest-recordings | Copy of your speaking recordings on this device | Until you sign out, delete the recording or clear your browser data |
5. Your account
- Data: name, email address, password (stored only as a cryptographic hash), interface language, time of sign-up, and for each sign-in session the IP address and browser.
- Email confirmation: we send a 6-digit code to confirm your address. It is stored only as a hash and expires after 10 minutes.
- Purpose and legal basis: creating and running your account (Art. 6(1)(b) GDPR); session data also for security, for example to detect misuse (Art. 6(1)(f) GDPR).
- Support access: to solve a problem you report or to check that the app works correctly, an authorised member of our team can open the app as you see it, including your progress, answers and feedback, for at most one hour at a time. These sessions are recorded with the team member's account. Legal basis: Art. 6(1)(b) and (f) GDPR.
6. Emails
We send emails that are needed for your account: confirmation codes, password resets and important notices about your account or subscription. We do not send newsletters. Emails are sent through Amazon Simple Email Service (Amazon Web Services); the email address, subject and content are processed on AWS servers in the USA. Legal basis: Art. 6(1)(b) GDPR. When you write to us, we use your message and email address to answer you.
7. Learning progress
Your answers, drafts, saved and completed tasks, flagged words, mock test results and whether you have seen the getting-started guide are stored in your account so you can continue on any device. Legal basis: Art. 6(1)(b) GDPR.
8. AI features
- Writing feedback: the text you typed, or a photo of your handwritten message, is sent together with the task to an AI model. We store the text (for photos, the transcript the model reads from it) and the feedback in your account. Photos are not stored.
- Speaking feedback: your recordings are stored in a private storage bucket in the EU (Amsterdam) and in your browser. For feedback, the recording (converted to an audio file) and the task, and for photo tasks the exam photo, are sent to an AI model. We store the transcript and the feedback.
- Study assistant: your questions, the previous messages of the conversation, the page you are on (including the German text of the task shown there) and your interface language are sent to an AI model. We store each question and answer with the page and time for 30 days to check the quality of the answers and prevent misuse, then delete them automatically. The conversation itself is only kept in your browser tab.
- Usage records: for every AI request we store the feature, model, number of tokens, cost and duration, to apply daily limits and control costs.
- Providers: AI requests go through OpenRouter, Inc. (USA), which forwards them to the provider of the model we use, currently Anthropic (Claude models, which may run on Amazon Web Services or Google Cloud) and Google (Gemini models). Request logging at OpenRouter is switched off for our account. The model providers process the content to generate the response and may keep it for a limited time for abuse and safety monitoring under their own terms.
- Legal basis: providing the features you use (Art. 6(1)(b) GDPR); keeping assistant conversations for 30 days and usage records: our legitimate interest in quality, cost control and preventing misuse (Art. 6(1)(f) GDPR). You can object to this (section 12).
- No automated decisions: feedback and estimated points are practice help only. They have no legal or similarly significant effect on you (Art. 22 GDPR does not apply).
- Please do not enter sensitive information or other people's personal data. For personal questions in the speaking tasks you can use invented details.
9. Payments
Subscriptions are sold by Polar Software, Inc. (USA) as merchant of record. Polar collects the data needed for the purchase (name, email address, billing address, payment details, IP address and country for tax purposes), processes payments through its payment providers (such as Stripe), and is responsible for this processing under its own privacy policy. We receive from Polar what we need to manage your subscription: customer and subscription ID, email address, plan, status, amount, country and dates. We never see your full card details. Legal basis: Art. 6(1)(b) GDPR, and Art. 6(1)(c) GDPR for records we must keep under accounting and tax law.
10. Service providers and transfers outside the EU
We use these providers. Railway, Cloudflare, Amazon Web Services and PostHog process data on our behalf under data processing agreements that are part of their terms of service. OpenRouter offers a data processing agreement only to enterprise customers, so we have none with it: we use OpenRouter under its terms of service and privacy policy, with request logging switched off for our account. We have no direct contract with Anthropic or Google; OpenRouter forwards our requests to them.
| Provider | Purpose | Location |
|---|---|---|
| Railway Corporation (USA) | Hosting, database, storage of recordings | Servers in the EU (Amsterdam); company in the USA |
| Cloudflare, Inc. (USA) | DNS, encryption, protection against attacks | Global network |
| PostHog, Inc. (USA) | Usage statistics for the website and the app | Servers in the EU (Frankfurt); company in the USA |
| Amazon Web Services (Amazon SES) | Sending emails | USA |
| OpenRouter, Inc. (USA) | Forwarding AI requests | USA |
| Anthropic and Google, possibly via Amazon Web Services or Google Cloud | AI models for feedback and the study assistant | USA and other regions |
| Polar Software, Inc. (USA) | Selling subscriptions, payments, invoices (independent controller) | USA |
For transfers to the USA we rely on the EU-US Data Privacy Framework where the recipient is certified under it (Art. 45 GDPR), and otherwise on the EU Standard Contractual Clauses in the providers' data processing agreements (Art. 46(2)(c) GDPR). AI requests are transferred to the USA through OpenRouter only when you use an AI feature, because this is necessary to provide it (Art. 49(1)(b) GDPR). You can ask us for a copy of the safeguards.
11. How long we keep data
| Data | Storage period |
|---|---|
| Account, progress, writing and speaking submissions, recordings, usage records | Until your account is deleted |
| Sign-in sessions (IP address, browser) | Until the session expires (up to 30 days) or you sign out |
| Confirmation codes | 10 minutes |
| Study assistant questions and answers | 30 days |
| Server logs at our providers | A short period, as set by the provider |
| Usage statistics (PostHog) | Up to 7 years |
| Subscription and invoice records | As required by accounting law, usually 7 years |
| Emails with us | As long as needed to handle your request |
12. Your rights
You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16) or deleted (Art. 17), to restrict processing (Art. 18), to receive it in a portable format (Art. 20), and to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you can withdraw it at any time with effect for the future.
To use your rights or to delete your account, write to [email protected] from the email address of your account. We answer within one month. When your account is deleted, we remove your account data, progress, submissions, recordings, assistant conversations and the usage statistics linked to your account ID; records we must keep by law are kept separately until the legal period ends.
You also have the right to complain to a data protection authority, in particular in the EU country where you live or work. Our lead authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, www.aki.ee.
13. Security
Connections are encrypted (HTTPS). Passwords are stored only as hashes, recordings are kept in a private storage bucket and are only accessible through short-lived links, and access to our systems is limited to what is needed to run the Service.
14. Minimum age
The Service is intended for people aged 16 and over. We do not knowingly process data of younger children.
15. Changes
We update this policy when the Service or the law changes. We will tell you about important changes by email or in the app. This English version is binding; the German and Turkish versions are translations.